BWV Camera Policy - UK Bailiffs
Body Worn Video Camera (BWVC) Policy
Introduction
At UK Bailiff Services, we are committed to professionalism, transparency, and public confidence in enforcement. This policy outlines how our self-employed enforcement agents must use body worn video cameras (BWVCs) during CRAR enforcement, High Court Writs of Control, Lease Forfeitures, and Temporary Housing Evictions.
Policy Statements
- Equipment Options:
As all enforcement agents are self-employed, they may either (a) supply and maintain their own BWVC, or (b) opt to rent a HALO 4G body worn camera supplied by UK Bailiff Services Ltd.
Where an agent chooses to supply their own BWVC, the device must meet the following minimum requirements:- Capable of recording both video and audio in high definition (minimum 720p resolution).
- Battery life sufficient to cover a minimum of 8 hours operational use without recharge.
- Secure storage with encryption and/or password protection to prevent unauthorised access.
- Time/date-stamped footage with tamper-evident controls; deletion/alteration must be logged.
- Ability to upload securely to the Company’s designated system within 12 hours of request.
- Durability suitable for outdoor operational use (weather-resistant/hard case recommended).
- Reliable file retention capacity to hold at least 90 days of recordings or facilitate offload to secure storage to meet this retention.
- HALO Camera Rental:
Where an agent chooses the rental option, a charge of £30 + VAT per month applies. This charge will only be levied if the agent has received at least two paid instructions during the same period. VAT invoices will be issued separately. Agents remain free to use their own compliant devices.
As part of the rental agreement, agents must take out and maintain adequate insurance to cover the rented equipment against loss, theft, or accidental damage. Proof of such insurance must be provided to UK Bailiff Services Ltd upon request.
Additional HALO BWVCs may be supplied to the Agent or their authorised substitutes upon request, at the same rate of £30 + VAT per month, subject to availability. - Mandatory Use During Visits: Agents must activate BWVCs as they approach a property and record the full duration of all enforcement attendances relating to CRAR, High Court Writs of Control, Lease Forfeitures, and Temporary Housing Evictions, unless recording becomes disproportionate or causes harm. (We do not encourage traveller/trespasser evictions due to their sensitivity.)
- Exceptional Circumstances: Recording may be paused briefly for private phone calls or sensitive situations, but agents must resume recording promptly. Any pauses must be justifiable and recorded verbally on camera where safe to do so.
- Privacy & Proportionality: Agents must balance accountability with privacy. Where safe and practical, agents should inform attendees that recording is in progress. Recording inside bedrooms, bathrooms, or where particularly sensitive health/financial information is being disclosed should be limited to what is necessary for evidential purposes.
- Audit Trail & Integrity of Evidence: Devices must generate an audit log(or equivalent record) showing activation/deactivation times and any access, export, deletion, or alteration of files. Audit logs and file hashes (where available) must be preserved with the footage to evidence integrity.
- Training & Competency: Agents must be familiar with BWVC operation, safe use, and data protection duties. Agents will complete initial familiarisation and, if requested by the Company, attend periodic refresher training or confirm completion of e-learning.
- Substitution & BWVC Compliance: Where an Agent appoints a substitute to undertake enforcement work, the substitute must (a) hold all necessary certification and authority, (b) comply fully with this BWVC Policy, and (c) have access to a compliant BWVC device (either a HALO rental allocated to the Agent or their own compliant device meeting the minimum requirements above). The Agent remains responsible for ensuring substitute compliance with BWVC requirements, including secure upload, retention, and data protection.
- No Routine Monitoring: Due to agents working across multiple companies and often owning their own devices, we do not access footage unless required for complaint resolution, compliance audits, or legal proceedings.
- Secure Upload on Request: In the event of a complaint, audit, Subject Access Request, or investigation, agents are required to upload footage securely to a specified system for internal review by our management team within the timeframe set.
- Data Retention: Agents are instructed to retain all BWVC footage for a minimum of 90 days. Footage linked to complaints, SARs, or legal matters must be retained until resolution/closure is confirmed by the Company.
- Restricted Access & Data Protection: Access to uploaded footage is limited to authorised managers only and is processed in accordance with the Data Protection Act 2018 and UK GDPR. Personal data captured is processed on a legitimate interests and/or legal obligation basis for accountability, safeguarding, and evidence.
- Sanctions for Non-Compliance: Agents who fail to comply with this policy may be removed from case allocation or our panel of approved contractors.
- Planned Improvements: We aim to roll out dedicated in-house BWVCs with automated upload features by October 2025 to further enhance compliance monitoring and audit capacity.
- Alignment with ECB Standards: This policy aligns with the Enforcement Conduct Board’s FS4 expectations on accountability, evidence handling, and agent oversight.
Conclusion
Body worn video is a critical tool for protecting the public, our agents, and the integrity of enforcement. This policy ensures that all enforcement visits are recorded fairly and that footage is handled securely and lawfully.
Policy Reviewed: September 2025
